Small mistake found with filed 5500

[Guest jc1457]

Hi,

We have a new client. While working on the 2010 Form 5500, the client realized that they included the wrong participant count information on the 2009 Form 5500-SF. On the 2009 Form 5500, the client reported 69 participants. In reality, they had 43. Everything else on the 2009 Form 5500-SF was correct.

My question is - would you amend for this? I know it is technically wrong but am not sure we should advise the client to amend. The client will do whatever we suggest.

Thank you!

[ETA Consulting LLC]

Flip a coin. I probably would because it is easy to do. And, you don't want your corrected numbers to trigger an audit for some reason like appearing to have a partial termination or something.

I still think it's a coin toss.

Good Luck!

[Andy the Actuary]

My preference since this is a material change is to amend. What participant count was used in the PBGC electronic filing? It should be consistent with the 5500-SF and if the 69 number, then a premium refund can be requested. Also, you'd want the PBGC filing to be requested. It's possible (how possible I don't know) but a drop from 69 to 43 participants on the PBGC filing might trigger the PBGC to look for the filing of Form 10, which was not filed.

[Guest jc1457]

My preference since this is a material change is to amend. What participant count was used in the PBGC electronic filing? It should be consistent with the 5500-SF and if the 69 number, then a premium refund can be requested. Also, you'd want the PBGC filing to be requested. It's possible (how possible I don't know) but a drop from 69 to 43 participants on the PBGC filing might trigger the PBGC to look for the filing of Form 10, which was not filed.

I'm sorry - I should have included this info. This is a defined contribution plan - a 403(b) plan. The employer relied on reports prepared by TIAA Cref. This year it was uncovered that the TIAA Cref counts for 2009 were inacurate. For 2010, we manually counted.

[Andy the Actuary]

I'm sorry - I should have included this info. This is a defined contribution plan - a 403(b) plan. The employer relied on reports prepared by TIAA Cref. This year it was uncovered that the TIAA Cref counts for 2009 were inacurate. For 2010, we manually counted.

In that case, never mind.